1. Governmentwide Commercial Purchase Card (GPC) Program Policies & Directives
Sheila McGlynn & Denise Reich
Office of the Under Secretary of Defense (OUSD)
Acquisition & Sustainment (A&S)—Used to be AT&L
Defense Procurement and Acquisition Policy (DPAP)—Soon to be Defense Pricing and Contracting (DPC)
Program Development and Implementation (PDI)
August 2018

2. Course Description
This session provides an overview of topical issues related to Department of Defense (DoD) policies, procedures and directives.

3. Acronyms CLIN Contract Line Item Number CO Commanding Officer
DoD FPI Federal Prison Industries (also known as UNICOR)
FMR DoD Financial Management Regulations
GPC Governmentwide Commercial Purchase Card
Guidebook DoD Charge Card Guidebook for Establishing & Managing Purchase, Travel & Fuel Card Programs - Effective 1 October New Release Dated January 24, 2018
IOD Insights On-Demand
JAM Joint Appointments Module
MPT Micro-Purchase Threshold
PAT Program Audit Tool
PBIS Procurement Business Intelligence Service
PCOLS Purchase Card On Line System
PCOM Purchase Card Oversight Module
PIEE Procurement Integrated Enterprise Environment
SAM System for Award Management
SAP/SAT Simplified Acquisition Procedures / Simplified Acquisition Threshold
STRL Science and Technology Reinvention Laboratories
Ts&Cs Terms and Conditions
WAWF Wide Area Workflow

4. Agenda SmartPay® 3 Task Orders and Transition Tasks
DoD Reporting Update
Strategic Sourcing Update
SP3 and Life After PCOLS and PAT
DoD PIEE Hierarchy
JAM
GPC Oversight Module
MPT Class Deviation Updates

5. Army/Air Force/Defense Agencies (A/AF/DA) and Navy SmartPay® (SP) 3 Task Orders

6. Status of Smart Pay 3 Army/Air Force/Defense Agencies and Navy Task Orders
U.S. Bank competitively awarded two DoD Tailored Task Orders (TTO) under GSA master contract GS-36-F-GA001:
A/AF/DA awarded on 21 June 2018
Navy awarded on 12 July 2018
Mastercard selected as Card Association under both TTOs
Mastercard/Insights on Demand (IOD) selected as Data Mining (DM) solution under both TTOs
DM continues in Purchase Card On-Line System [A/AF/DA] and Program Audit Tool [Navy] until end of SP2 [29 November 2018]
IOD to be used for DM Department-wide throughout SP3 transactional period [beginning 30 November 2018]

7. Requirements under SP 3 A/AF/DA and Navy Task Orders
Both TTOs have:
13 year maximum transactional period of performance (4 year base period; three 3 year option periods)
SP2 Accounts no longer Valid: November 11:59pm
SP3 Accounts Active: November 12:00am
Tailored refund calculations
Tailored DoD Procurement Integrated Enterprise Environment (PIEE)/Joint Appointment Module (JAM) requirements
Tailored financial management and other system interface requirements
Tailored reporting requirements
Tailored Electronic Access System
Tailored Data Mining (DM) requirements
DPAP worked with Services to review data mining rules to determine which to include in SP3 to improve identification of infractions
Included selected business rules in A/AF/DA and Navy SP 3 task orders
Established semi-annual governance process for reviewing/updating rules as necessary

8. How Refunds Will Change Under SmartPay 3 Task Orders
SP 2
Complex calculations to account for separate sales and productivity refunds
SP 3:
Combined refund rates, taking into account sales volume and speed-to-pay
Separate “Standard” and “Large Ticket” transaction refund CLINs
Lower SP 3 refunds will be paid for Large Ticket transactions, based on applicable lower interchange fees. Master contract does not provide a dollar threshold for large ticket items. Currently, for Mastercard, large ticket transactions apply to non-travel card transactions that provide Level 3 (Line Item detail/SKU) data and are over $7,255 for domestic US transactions.
Speed-to-pay accounted for via refund basis points “day-banding” for all Standard and Large Ticket Transaction CLINs
Anticipated that throughout SP 3 transactional period, DPAP will require components to certify the accuracy of their Quarterly refund statements from US Bank.

9. How Refunds Will Change Under SmartPay3 Task Orders (cont)
Day-bands for Standard and Large Ticket Transaction CLINs:*
A/AF/DA TTO:
0 – 8 Calendar Days**
9 – 19 Calendar Days
20 – 30 Calendar Days
31+ Calendar Days
Navy TTO:
9 – 15 Calendar Days
16 – 22 Calendar Days
23 – 29 Calendar Days
30 – 43 Calendar Days
44 – 50 Calendar Days
50+ Calendar Days
*Separate basis points for each day band applicable for standard versus large ticket transactions.
**Calendar days from statement date, with clock starting with accessibility of invoice in EAS/delivery of the file to ERP
Note: SP3 refund process has no effect on reconciliation and certification process/timeline:
1) CH must reconcile and certify monthly Statement of Account -- best practice: within 3 business days of billing cycle end date to maximize refunds and prevent interest penalties.
2) AO must promptly review and certify CH statements of account -- best practice: within 5 days of the billing cycle end date. 

10. SP 3 Transition Tasks for Program Officials

11. Prior to 29 November 2018 Card and convenience check holders:
Follow agency policy for disposing of GSA SP2 cards and unused convenience checks
Cancel all recurring charges on SP2 card
Promptly reconcile all transactions
Adhere to Charge Card Guidebook and any component record retention policies
Activate new account following card receipt
Complete all required training
Adhere to forthcoming DPAP policy memo on orderly shutdown of SP2 accounts
Submit any dispute or fraud information to US Bank
AO and A/BOs:
Ensure all accounts are reconciled promptly

12. Prior to 29 November 2018 A/OPCs:
In accordance with forthcoming DPAP instructions, go into Access Online to:
Validate SP2 account Information
Validate user ID Information
Ensure financial managers validate accounting Information
Confirm TBR hierarchy – moving to all new managing and cardholder accounts allows for reorganization for efficiency or functionality
Designate SP2 accounts for replication [ie: retention in SP3] or termination
Record SP3 card delivery instructions if desired
Enter “home organization” and “role location” Department of Defense Activity Address Codes (DoDAAC)
ASAP work with your Group Administrator (GAM) to validate your PIEE hierarchy
If you don’t yet have one, create WAWF/PIEE account
Complete all required training

13. DoD Reporting Update

14. DoD Reporting Update
Issued “DoD GPC Disciplinary Category Definitions Guidance Memo” in July 2017 to eliminate reporting inconsistencies within the Department. Memo:
Provided interim definitions and examples of categories (abuse, internal fraud, misuse, and delinquency [violations], administrative discrepancy, and external fraud)
Required Quarterly and Semi-annual reporting to OMB on the 4 violation categories
Updates:
DPAP’s Quarterly & Semi-Annual Reporting Guidance updated based on OMB’s 2017 memo M-17-26, “Reducing Burden for Federal Agencies by Rescinding and Modifying OMB Memoranda”
Memo made Quarterly Statistical Reporting “optional and not required to be submitted to OMB”
As memo requires DoD “to maintain statistical and narrative information for their own use and management of their charge card program,” DPAP still collects Quarterly and Semi-Annual data from components, but no longer forwards data to OMB
Under the SP3 transactional period, components will be required to report to DPAP on all 6 disciplinary categories, beginning:
Quarterly – FY19 Q2
Semi-Annual – FY19 Q1-Q2
Work continues to automate DoD Reporting within Procurement Business Intelligence Service
Above actions responsive to DoD IG Audit D2017-D000CL-0045

15. Strategic Sourcing Update

16. Strategic Sourcing Update
In response to GAO , “GOVERNMENT PURCHASE CARDS: Opportunities Exist to Leverage Buying Power,” dated May 19, 2016:
DPAP issued September 2016 guidance memorandum entitled "Opportunities to Leverage Buying Power with Purchase Cards" requiring DoD Components to implement GAO's recommendations. Actions taken to implement memo:
 DFARS updated to include DPAP memo requirements; went into effect 1 October 2017
 During 2017, components conducted purchase card spend analysis, identified possible savings, and made broader applicability determinations; Services briefed DPAP Acting Director on findings
Purchase card strategic sourcing language drafted by DPAP and forwarded to Defense Contract Management Agency for incorporation into Program Management Review Manual; Manual updated in April 2018

17. Strategic Sourcing Update (cont)
Based on actions taken, DPAP memo “Recommendation Closure Request on GAO report, GAO , ‘Government Purchase Cards: Opportunities Exist to Leverage Buying Power,’ May 19, 2016” signed June 27, 2018, recommended closure of report recommendations pertaining to DoD GPC.   Actions for Components going forward:
Components shall periodically analyze purchase card transaction data and spend patterns to identify opportunities to obtain savings
Components shall periodically determine the feasibility for broader application of these efforts across the agency
Be prepared to address the following during PMRs:
Has the agency periodically analyzed purchase card transaction data and spend patterns to identify opportunities to obtain savings?
Has the agency periodically determined the feasibility for broader application of these efforts across the agency?

18. SP3 and Life After PCOLS and PAT

19. Procurement Integrated Enterprise Environment (PIEE)
WAWF
rebranded as
PIEE
Adding
GPC
Applications

20. PIEE Overview
PIEE Overview

21. SmartPay® 2 » SmartPay® 3 System Transition
Hierarchy
Delegation & Appointment
System Access
Account Issuance & Maintenance
EMMA
TBR
PIEE
TBR
JAM
PCOLS
EAS
PIEE
PCOLS
EAS
Paper
EAS
TBR
EAS
Oversight
Invoice Certification
& Payment
Reporting
Archive
Data Mining
PCOLS
EAS
IOD
EAS
PCOLS
PCOM
EAS
IOD
PCOLS
EAS
PIEE
PBIS
EAS DM
PBIS
EAS
EAS
ERPs
Accounting Systems
EAS
ERPs
Accounting
Systems
EAS
DMDC
PAT
EAS
PAT
PAT
EAS

22. Getting Ready for The PIEE Hierarchy
All Component’s have an existing PIEE Hierarchy
Already agreed to and “fixed” through Level 3
Defense Agency GPC Level 3s moved to Level 2 Component Program Managers (CPMs)
Component Group Administrators (GAMs) “own” and are responsible for coordinating changes at Level 4 and below
U.S. Bank required to report up the PIEE hierarchy
All A/OPCs must work with their local PIEE GAM now to:
Understand their Component’s hierarchy
Identify Home Organization DoDAACs for the organizations they support
SP3 Transition offers A/OPCs the opportunity to evaluate and update their TBR Hierarchies to support reporting needs
Engage your Component Financial Manager and U.S. Bank Customer Relationship Manager
Finalize changes NLT 15 September to support SP3 Card Issuance

23. DoD Activity Address Code (DoDAAC)
Accurate DoDAAC entry by all users during PIEE registration is ESSENTIAL for successful deployment.
A DoDAAC is a DoDAAC, but one DoDAAC can be flagged to identify its different attributes (e.g., Procurement, Ship to, Funding)
For GPC Program purposes there are 3 DoDAAC “types” to focus on:
Home Organization DoDAAC – “I physically sit here”
Role Location DoDAAC – “I perform my duties here”
Authority Location DoDAAC – “I got my appointment from here”
All delegations of authority must emanate from an organization that has procurement authority, but PIEE will not enforce this until a later date.
Regarding the last bullet on Procurement Authority - The goal is to get everyone into the application without interruptions to services before we move in that direction
And I’m Wanda. We’re going to help you understand DoDAACs.
Hi! I’m Dave.

24. DoDAACs

25. Getting Ready for The Joint Appointments Module (JAM)
Will be used to issue GPC Delegation of Authority & Appointment Letters and Certifying Officer Appointments
CH single purchase limit in the EAS will be capped by JAM delegated limit
All A/OPCs must:
Request PIEE Access (~45% of A/OPC already have PIEE accounts)
Work with their local PIEE GAM to establish GPC access protocols
Identify Home Org DoDAACs1 for each organization to which they provide GPC accounts
Identify the Home Org DoDAAC2 for person who will sign their GPC Delegation or Appointment Letter
PCOLS Active Account Data will be used to assist with migration
Account and Training Data
Phase 1
Component PM , Oversight A/OPC (With or Without Delegating Authority), A/OPC (With or Without Delegating Authority)
Phase 2
Approving Official, A/BO, Cardholder, GPC Certifying Officer
1 This is YOUR Role Location DoDAAC
2 This is YOUR Authority Location DoDAAC

26. GPC Data Mining and Oversight
Transactions will be referred to the A/BO daily
Timely completion of Questionnaire required
Delayed responses will result in automatic account suspensions
A/OPC required to:
Validate review 100% of DM cases and enter corrective action taken for all cases of improper GPC use. Work with Supervisors as appropriate.
Open DM cases for all improper GPC use otherwise identified. Supports automated GPC “Violations” Reporting.
Brief Commander every 6 months to obtain signature of Semi-Annual PMR Report
Oversight A/OPCs required to:
Review Closed Cases, and Monthly and Semi-Annual PMR Reports
CPM required to:

27. Planned GPC Oversight Process
Policy Not Yet Finalized

28. Quarterly Data Mining Case Validation Reviews
Daily DM Case Reviews
Semi-Annual PMRs
Monthly PMRs
Purpose:
Detect/Prevent Improper GPC Use
Document Corrective Actions
Players:
A/BOs & AOs
A/OPCs
Supervisors
Process:
Insights On-Demand (IOD) Flags Transactions for Review
A/BOs Review & Close Cases
A/OPC Verify All A/BO Results & Document Corrective Action
Supervisor & A/OPC collaborate to take Personnel Action As Necessary
Product:
Closed Cases / Corrective Action
Purpose:
Document Oversight Actions
Review Internal Controls
Ensure DM Case Closure
Engage Supervisors
Players:
Supervisors
A/OPCs
OA/OPCs
Process:
A/OPC:
Verifies 100% DM Case Closure
Reviews Key Internal Controls
Documents Findings (+ / -)
OA/OPC
Reviews A/OPC Submissions
Reviews Summary Data
Affirm Accounts Needed
Product:
Monthly PMR Report
Purpose:
Ensure Leadership Insight
Enable Organizational / Strategic Decision Making
Players:
A/OPCs
OA/OPCs
CPMs
Commanding Officers (COs) / Procurement Leads / SPEs
DPAP
Process:
COs at Each Level Receive Program Briefings from their A/OPCs, OA/OPCs or CPMs and Sign-Off
A/OPCs, OA/OPCs or CPMs Affirm Completion
CPMs Provide Brief to DPAP
Product:
Semi-Annual PMR Report
Open Cases Result
In Automatic
Account Suspensions
Quarterly Data Mining Case Validation Reviews
Procurement Management Reviews / Internal Control Reviews / IG Reviews

29. Planned Quarterly DM Case Validation Reviews
Purpose:
Independent validation that A/BO, AO and A/OPC’s are doing due diligence when conducting GPC DM Case Reviews and Documenting Corrective Action Taken (i.e., Confirm/Refute case disposition status)
Players:
GPC Subject Matter Experts (SMEs) identified by OSD & Components to serve for fixed terms
Process:
A system-generated, statistically significant random sample of closed DM Cases will be reviewed by a SMEs quarterly
Each improper/questionable case closure finding will be referred back to the Component Program Manager (CPMs) for action (e.g., refer back to A/OPC or perform independent review).
Product
A/OPCs, OA/OPCs and CPMs will address resolution for improper/questionable case closure findings during Semi-Annual PMR Briefings.  

30. Micro-Purchase Threshold Class Deviation Update 2018-O0013 of 4/13/ O0007 of 9/1/ O0006 of 7/21/2017 and 21 July 2017 GPC Policy Memo

31. This is for high tech purchases, not SF-182 Training
Class Deviation 2018-O0013
Issued 13 April 2018
Creates $10K (or higher) “Higher Ed” MPT - Supplies or services from:
Institutions of higher education
Related or affiliated nonprofit entities
Nonprofit research organizations
Independent research institutes
Construction and Services thresholds remain in effect:
Construction1 ($2,000)
Services2 ($2,500)
Changes the thresholds for small business set-aside from “$3,500” to "the micro-purchase threshold“ (FAR Parts 13 & 19)
NOTE: Cardholders still must comply with FAR Part 8 FPI regulatory requirements between $3, and the MPT
This is for high tech purchases, not SF-182 Training
Footnotes:
For construction acquisitions subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements
For services acquisitions subject to 41 U.S.C. chapter 67, Service Contract Labor Standards

32. Federal Prison Industries (AKA: UNICOR) New GPC Procedures
March 13, 2016
FPI Board of Directors $3,500
Blanket Waiver Remains in Effect*
Federal Prison Industries (AKA: UNICOR) New GPC Procedures
* See

33. FPI Purchasing Decision Framework
CH Receives Requirement
Valued Above $3,500
KO2B authorizes Alternate Source?
Follow Existing
Micro-Purchase Procedures Y
Purchase following Micro-Purchase Procedures.
If soliciting offers, FPI must be included.
CH2A
Market Research indicates comparable? N
Mandatory
FPI Item?1 Y Y
Waiver Requested & Granted by FPI?
Purchase from FPI N N N Y
Make Purchase Following Existing
Micro-Purchase Procedures
Indicates CH Option

34. FPI Purchasing Decision Framework - Notes
Check FPI Web Page to determine if:
DoD Purchases of Mandatory FPI Supplies in FSCs for which FPI's share of the DoD Market is greater than 5%
Item that FPI is the mandatory supplier
A) CH market research indicates; and
B) KO issues a written determination the FPI item is not comparable to supplies available from the private sector that best meet the Government’s needs in terms of price, quality, and time of delivery . [FAR 8.602]

35. MPT Class Deviation Guidance & Implications

36. Dod GPC Guidance
The Guidebook requires spending limits be set considering historical spending patterns to minimize DoD’s Charge Card violation risk
Raise and then lower Single Purchase Limits for CHs who rarely (or seasonally) make purchases requiring the higher MPT
Only grant authority to CHs who:
are likely to require it
have been trained to follow FPI purchasing and waiver request procedures [FAR 8.605]
CH Single Purchase Limits can never exceed the CH’s delegated authority
New Delegation Letters must be issued and countersigned as required
Basic Research Program GPC micro-purchases valued above $5,000 must be made on a CH account issued solely for that purpose
Anticipate Higher Ed MPT will not be used for GPC purchases because Ts & Cs will be required
To comply with DFARS if HCA authorized “higher MPT”, the GPC must be specified as the method of payment and WAWF Receiving Report utilized to document acceptance
All CH’s Single Purchase Limits
Should NOT Be Automatically Increased
Dedicated Special Use Account Required

37. Raises the DoD “General" SAT from $150,000 to $250,000
Summary of Changes from Class Deviations 2017-O0007 to 2018-O0013 Changes
Adds subparagraph (5) to FAR MPT Definition – Aluthorizes$10K (or higher) MPT for acquisitions of supplies or services from institutions of higher education (20 U.S.C (a)) or related or affiliated nonprofit entities, or from nonprofit research organizations or independent research institutes
DFARS further delegates “Head of the Contracting Activity” authority to increase this MPT—
consistent with clean audit findings, an internal institutional risk assessment, or state law
Changes the Small Business Set-Aside thresholds from fixed values to "micro-purchase threshold“ and “simplified acquisition threshold” in FAR Parts 13 & 19
Eliminates the GPC small business set-asides requirements between $3,500 and $5,000 that resulted from the FY 17 NDAA
Raises the DoD “General" SAT from $150,000 to $250,000
Adds “to support a request from the Secretary of State or the Administrator of the United States Agency for International Development to facilitate provision of international disaster assistance pursuant to 22 U.S.C et seq
Raises the “Humanitarian and Peace Keeping” SAT to $500K outside the U.S.
This is not for use with
SF-182 Training

38. Simplified Acquisition Threshold
Category
Inside U.S.
Outside U.S.
General DoD SAT
$250,000
Acquisitions of supplies or services that, as determined by the head of the agency, are to be used to:
Support a Contingency Operation
Facilitate defense against or recovery from the following types of attacks:
Cyber
Nuclear
Biological
Chemical
Radiological
Support a request from the Secretary of State or the Administrator of the United States Agency for International Development to facilitate provision of international disaster assistance pursuant to 22 U.S.C et seq.
Support a Response to:
Emergency
Major Disaster
$750,000
$1,500,000
Support a Humanitarian or Peacekeeping Operation (10 U.S.C. 2302)
N/A
$500,000

39. How Does the SAT Impact the GPC Program
Contingency Contracting Officers may “use the GPC” up to:
$750K Inside the U.S.
$1.5M Outside the U.S.
DFARS (3)
(3) A contracting officer supporting a contingency operation as defined in 10 U.S.C. 101(a)(13) or a humanitarian or peacekeeping operation as defined in 10 U.S.C. 2302(8) also may use the Governmentwide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed the simplified acquisition threshold, if--
(i) The supplies or services being purchased are immediately available;
(ii) One delivery and one payment will be made; and
(iii) The requirements of paragraphs (2)(i) and (ii) of this section are met.

40. DFARS 213.301(2) – GPC Use Outside the U.S.
(2) An individual appointed in accordance with (b) also may use the Governmentwide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed $25,000, if—
(i) The purchase—
(A) Is made outside the United States for use outside the United States; and
(B) Is for a commercial item; but
(C) Is not for work to be performed by employees recruited within the United States;
(D) Is not for supplies or services originating from, or transported from or through, sources identified in FAR Subpart 25.7;
(E) Is not for ball or roller bearings as end items;
(F) Does not require access to classified or Privacy Act information; and
(G) Does not require transportation of supplies by sea; and
(ii) The individual making the purchase—
(A) Is authorized and trained in accordance with agency procedures;
(B) Complies with the requirements of FAR in making the purchase; and
(C) Seeks maximum practicable competition for the purchase in accordance with FAR (b).
DFARS does not add these to the MPT Definition

41. What’s Happening with the MPT?

42. Micro-Purchase Thresholds
CURRENT MICRO-PURCHASE THRESHOLDS
Threshold 1
Non-DoD Federal-wide Open Market Micro-Purchase
$10,000 2
DoD GPC Open Market Micro-Purchase (General)
$5,000 3
DoD GPC Open Market Micro-Purchase (STRLs and Basic Research Programs) 4
Federal-wide Higher Education Open Market Micro-Purchase
$10,000 or Greater 5
GPC Construction
$2,000 6
GPC Service Contract Labor Standard Services
$2,500 7
GPC Contingency (Inside US)
$20,000 8
GPC Contingency (Outside US)
$30,000

43. “Contingency Contracting” Micro-Purchase Thresholds
Category
Inside U.S.
Outside U.S.
Acquisitions of supplies or services that, as determined by the head of the agency, are to be used to:
Construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction) (41 U.S.C. 1903)
$2,000
Support a Contingency Operation
Facilitate defense against or recovery from the following types of attacks:
Cyber
Nuclear
Biological
Chemical
Radiological
Support a request from the Secretary of State or the Administrator of the United States Agency for International Development to facilitate provision of international disaster assistance pursuant to 22 U.S.C et seq.
Support a Response to :
Emergency
Major Disaster
$20,000
$30,000
Support a Humanitarian or Peacekeeping Operation (10 U.S.C. 2302)
Not Addressed

44. FY 2019 National Defense Authorization Act Conference Report
SEC INCREASE IN MICRO-PURCHASE THRESHOLD APPLICABLE TO DEPARTMENT OF DEFENSE.
IN GENERAL.—Section 2338 of title 10, United States Code, is amended by striking:
‘‘Notwithstanding 5 subsection (a) of section 1902 of title 41, the micro-purchase threshold for the Department of Defense for purposes of such section is $5,000’’
and inserting:
‘‘The micro-purchase threshold for the Department of Defense is $10,000’’.
NOTE:
Removes STRL and Basic Research Programs language that served as a ceiling
Convenience Check Threshold is $5,000
PENDING CONGRESSIONAL
ACTION

45. Anticipated FY 2019 Micro-Purchase Thresholds
Threshold 1
Federal-wide Open Market Micro-Purchase
$10,000 2
Federal-wide Higher Education Open Market Micro-Purchase
$10,000 or Greater 3
GPC Construction
$2,000 4
GPC Service Contract Labor Standard Services
$2,500 5
GPC Contingency (Inside US)
$20,000 6
GPC Contingency (Outside US)
$30,000
POSSIBLE FUTURE MICRO-PURCHASE THRESHOLDS
Threshold
GSA e-Commerce Portal (not FedMall or GSA Advantage)
$25,000
In Case You Hear Something About This…

46. DoD Micro-Purchase Regulations

47. What is a Micro-Purchase (FAR 2.101)?
Acquisition.gov FAR Site
“Micro-purchase” means an acquisition of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold.
Hill AFB FAR Site - Missing Important Words
“Micro-purchase” means an acquisition of supplies or services, the aggregate amount of which does not exceed the micro-purchase threshold.
SAP (FAR 13) does not include the following, so they are not micro-purchases:
Placing Orders against Contracts (FAR 16.5)
Placing Orders against GSA Schedules (FAR 8.405)
Purchasing from FPI (FAR 8.6)
Overseas GPC Use up to $25K (DFARS (2))
Contract Payments (FMR)
SF-182 Payments (FMR)
Intergovernmental Payments (FMR)
GPC Micro-Purchase Appointment is not sufficient for CHs taking these actions.

48. What Are the Two Available Contracting Authorities?
Appointment.
(a) Contracting officers shall be appointed in writing on an SF 1402, Certificate of Appointment, which shall state any limitations on the scope of authority to be exercised, other than limitations contained in applicable law or regulation. Appointing officials shall maintain files containing copies of all appointments that have not been terminated.
(b) Agency heads are encouraged to delegate micro-purchase authority to individuals who are employees of an executive agency or members of the Armed Forces of the United States who will be using the supplies or services being purchased. Individuals delegated this authority are not required to be appointed on an SF 1402, but shall be appointed in writing in accordance with agency procedures.
Selection.
 (1) In accordance with 10 U.S.C. 1724, in order to qualify to serve as a contracting officer with authority to award or administer contracts for amounts above the simplified acquisition threshold, a person must— [Education and DAWIA Requirements]
Appointment.
 (b) Agency heads may delegate the purchase authority in to DoD civilian employees and members of the U.S. Armed Forces.
This limits DoD Agency Heads from delegating authority to non-DoD Federal Employees

49. How Do These Relate to Available JAM Cardholder Appointments?
Authority Type
Threshold
Warrant Issued? 1
Micro-Purchase Cardholder
$5K 2
Micro-Purchase Convenience Check Writer 3
Higher Education Micro-Purchase Cardholder
$10K - but HCA determination can result in higher value (unlimited) 4
Micro-Purchase Contingency Contracting Cardholder
$20K Inside the US
$30K Outside the US 5
Warranted Contingency Contracting Cardholder
$750 Inside the US;
$1.5M Outside the US  6
Contract Ordering Official Cardholder
Simplified Acquisition Threshold 7
Overseas Simplified Acquisition Cardholder
$25K 8
Contract Payment Official Cardholder
Unlimited 9
SF-182 Training Payments Cardholder 10
Inter/Intra-Governmental Payment Official Cardholder
$24,999
[1] GPC Delegation of Authority and Appointment Letter is equivalent to appointment on as SF-1402, Certificate of Appointment (i.e., Contracting Officer Warrant).

50. Questions?

51. Back Up

52. GPC Overseas Use up to $25K

53. GPC Use Outside the United States
These GPC purchases are simplified acquisitions, but not micro-purchases
DFARS (2) authorizes GPC CH to use the GPC to make a purchase that exceeds the MPT but does not exceed $25,000, if—
(i) The purchase—
(A) Is made outside the United States for use outside the United States; and
(B) Is for a commercial item;
(C) Is not for work to be performed by employees recruited within the United States;
(D) Is not for supplies or services originating from, or transported from or through, sources identified in FAR Subpart 25.7 [Prohibited Sources];
(E) Is not for ball or roller bearings as end items;
(F) Does not require access to classified or Privacy Act information; and
(G) Does not require transportation of supplies by sea; and
(ii) The individual making the purchase—
(A) Is authorized and trained in accordance with agency procedures;
(B) Complies with the requirements of FAR [Mandatory Sources] in making the purchase; and
(C) Seeks maximum practicable competition for the purchase in accordance with FAR (b).

54. GPC Use Outside the U.S. – Price Reasonableness / Competition Standard
FAR Promoting Competition
(b) If using simplified acquisition procedures and not providing access to the notice of proposed contract action and solicitation information through the Governmentwide point of entry (GPE), maximum practicable competition ordinarily can be obtained by soliciting quotations or offers from sources within the local trade area.
Unless the contract action requires synopsis pursuant to and an exception under is not applicable, consider solicitation of at least three sources to promote competition to the maximum extent practicable. Whenever practicable, request quotations or offers from two sources not included in the previous solicitation.

55. Overseas Regulatory Relief for DFARS 213.301(2) GPC purchases
Subpart 4.11—System for Award Management
CH reaching back to US vendor must verify SAM registration
Subpart 5.2—Synopses of Proposed Contract Actions
Synopsis required if soliciting from other than local vendors for purchases > $15K
Subpart 8.605—Acquisition from Federal Prison Industries, Inc.
Do not need to purchase or request waiver from FPI when the supplies are acquired and used outside the United States
Subpart 9.1—Responsible Prospective Contractors
Applies unless it conflicts with local law or customs
Part 19—Small Business Programs Small Business Set-Aside requirements not applicable
This part, except for Subpart 19.6*, applies only in the United States or its outlying areas. Subpart 19.6 applies worldwide.
If reaching back to U.S. above the MPT, it must be set aside for small business.
* Certificates of Competency and Determinations of Responsibility

56. Federal Prison Industries (AKA: UNICOR) Detailed Slides
March 13, 2016
FPI Board of Directors $3,500
Blanket Waiver Remains in Effect*
Federal Prison Industries (AKA: UNICOR) Detailed Slides
* See

57. FPI Purchasing Decision Framework
CH Receives Requirement
Valued Above $3,500
KO2B authorizes Alternate Source?
Follow Existing
Micro-Purchase Procedures Y
Purchase following Micro-Purchase Procedures.
If soliciting offers, FPI must be included.
CH2A
Market Research indicates comparable? N
Mandatory
FPI Item?1 Y Y
Waiver Requested & Granted by FPI?
Purchase from FPI N N N Y
Make Purchase Following Existing
Micro-Purchase Procedures
Indicates CH Option

58. FPI Purchasing Decision Framework - Notes
Check FPI Web Page to determine if:
DoD Purchases of Mandatory FPI Supplies in FSCs for which FPI's share of the DoD Market is greater than 5%
Item that FPI is the mandatory supplier
A) CH market research indicates; and
B) KO issues a written determination the FPI item is not comparable to supplies available from the private sector that best meet the Government’s needs in terms of price, quality, and time of delivery . [FAR 8.602]

59. Purchasing From Federal Prison Industries
Follow FAR Mandatory Government Sources Priority List
(1) Supplies.
(i) Inventories of the requiring agency.
(ii) Excess from other agencies (see subpart 8.1).
(iii) Federal Prison Industries, Inc. (see subpart 8.6)
(iv) Supplies which are on the Procurement List maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled (AKA AbilityOne) (see subpart 8.7).
(v) Wholesale supply sources, such as stock programs of the General Services Administration (GSA) (see 41 CFR ), the Defense Logistics Agency (see 41 CFR ), the Department of Veterans Affairs (see 41 CFR ), and military inventory control points.
(2) Services. Services that are on the Procurement List maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled (see subpart 8.7).
NOTE: FPI is higher priority for Supplies; AbilityOne is higher priority for Services. [FAR & 8.002]

60. Purchasing From Federal Prison Industries
Purchase from FPI is not mandatory & a waiver is not required if:
Acquiring supplies totaling $3,500 or less [FAR 8.605(e)]
FPI is not a mandatory supplier for the supply being purchased
For DoD Purchases of Mandatory FPI Supplies in FSCs for which FPI's share of the DoD Market is greater than 5%
Contracting Officer determines the mandatory supply is not comparable to supplies available from the private sector that best meet the Government’s needs in terms of price, quality, and time of delivery. [FAR 8.602]
CH appointed in accordance with FAR are not Contracting Officers
The CH requests and FPI grants a purchase waiver [FAR 8.604]

61. FPI Product and Service Categories
Source:

62. Mandatory from FPI?
Source:

63. DoD 5% Market Share Exception List (Current on 7/29/17)
Source:

64. FPI GPC Price Reasonableness / Competition Standard
Micro-Purchase Purchasing Guidelines
(i.e., Applicable Competitive Procedures)
Micro-purchases shall be distributed equitably among qualified suppliers
Micro-purchases may be awarded without soliciting competitive quote if cost to solicit offers exceeds expected savings, and the KO or CH considers the price to be reasonable [FAR ]
CH has recently purchased the item on a competitive basis [reviewed 3 quotes]
CH does not suspect or have information indicating the price may not be reasonable

65. Regulations & Guidance That Often Come Up

66. No Change to Construction, Service Contract and Contingency Thresholds
FAR 2.101
“Micro-purchase” means an acquisition of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold. “Micro-purchase threshold” means $3,500, except it means— (1) For acquisitions of construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction), $2,000; (2) For acquisitions of services subject to 41 U.S.C. chapter 67, Service Contract Labor Standards, $2,500; and (3) For acquisitions of supplies or services that, as determined by the head of the agency, are to be used to support a contingency operation or to facilitate defense against or recovery from nuclear, biological, chemical or radiological attack as described in (g)(1), except for construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction) (41 U.S.C. 1903)— (i) $20,000 in the case of any contract to be awarded and performed, or purchase to be made, inside the United States; and (ii) $30,000 in the case of any contract to be awarded and performed, or purchase to be made, outside the United States.
No Change to Construction, Service Contract and Contingency Thresholds

67. FAR 13.203 - Micro-purchase Purchase Guidelines
(a) Solicitation, evaluation of quotations, and award.
(1) To the extent practicable, micro-purchases shall be distributed equitably among qualified suppliers.
(2) Micro-purchases may be awarded without soliciting competitive quotations if the contracting officer or individual appointed in accordance with (b) considers the price to be reasonable.
(3) The administrative cost of verifying the reasonableness of the price for purchases may more than offset potential savings from detecting instances of overpricing. Therefore, action to verify price reasonableness need only be taken if --
(i) The contracting officer or individual appointed in accordance with (b) suspects or has information to indicate that the price may not be reasonable (e.g., comparison to the previous price paid or personal knowledge of the supply or service); or
(ii) Purchasing a supply or service for which no comparable pricing information is readily available (e.g., a supply or service that is not the same as, or is not similar to, other supplies or services that have recently been purchased on a competitive basis).
(b) Documentation. If competitive quotations were solicited and award was made to other than the low quoter, documentation to support the purchase may be limited to identification of the solicited concerns and an explanation for the award decision.

68. FPDS Contract Reporting DFARS PGI 204.6
(5) Reporting task and delivery orders where the Governmentwide commercial purchase card is both the method of purchase and payment. (i) Do not report open-market purchases (i.e., not under a Federal Supply schedule, agreement, or contract) made with the Governmentwide commercial purchase card valued less than the micropurchase threshold to FPDS. (ii) Purchases made using the Governmentwide purchase card as the method of both purchase and payment under federal schedules, agreements, or contracts are required to be reported to FPDS regardless of value. Contracting offices shall ensure all such purchases made by their authorized cardholders are reported to FPDS no less frequently than monthly. Any individual purchase valued greater than $25,000 must be reported individually to FPDS. For individual purchases valued less than $25,000, there are three acceptable methods for reporting to FPDS. They are, in preferred order of use: (A) Report each order individually to FPDS; (B) Report a consolidated express report to FPDS using the delivery order or BPA call format that references the individual contract or BPA, respectively; or (C) Report a consolidated express report to FPDS using the purchase order format that uses the generic DUNS for ‘GPC Consolidated Reporting’ or for ‘GPC Foreign Contractor Consolidated Reporting’, as appropriate, as the identifier. Note that when a generic DUNS number is used to report these actions, only ‘Other than Small Business’ is allowed as the ‘Contracting Officer’s Determination of Business Size’ selection.
When the GPC is used solely as a method of payment method against a contract,
report the action as any other individual contract action report.
Mark ‘Purchase Card as Payment Method’ as ‘Yes’.

69. SF 182 Training Request Payments Guidebook A.1.3
Mandatory: The GPC shall be the method of payment for all commercial training requests using the SF 182, valued at or below $25,000, in lieu of an employee reimbursement by miscellaneous payment in accordance with the procedures to directly pay the provider in DoD FMR Volume 10, Chapter 12, Section , and DoDI , Volume 410.
Title 5 U.S.C., Section 4109 authorizes the head of an agency, under the regulations prescribed in 5 U.S.C. 4118(a)(8), to reimburse employees for necessary training expenses (e.g., tuition and matriculation fees; library and laboratory services; purchase or rental of books, materials, and supplies; and other services or facilities directly related to employee training). Therefore, training, education, and professional development SF-182 actions are not FAR-based transactions. See DoDI , Volume 410 for additional information regarding the appropriate use of the SF 182.
The total price of training authorized by the use of a single SF 182 may not exceed $25,000 in accordance with DoD FMR Volume 10, Chapter 12, Paragraph SF-182 authorized training may be provided by Government or non-Government sources. When training is provided by a non-Government source, in order to be eligible for GPC payment via the SF-182 process it must consist of a regularly scheduled, commercial-off-the-shelf (COTS) course, training conference, or instructional service that is available to the general public and priced the same for everyone in the same category; e.g., price per student, course, program, service, or training space.
Mandatory: If the Government has a need for tailored training or tailored training materials, the requirement shall be placed on Government contract by a warranted contracting officer.